Purpose
Bank of Hope and its affiliates (“Bank”) expect that each third-party supplying products and/or service to Bank (“Third Party”) behave ethically, conduct its business with integrity, and comply with all applicable laws. This Third Party Code of Conduct (“Code”) sets forth the minimum standards Third Parties, as well as Third Party officers, directors, employees, and subcontractors are required to operate under when conducting business with and on behalf of Bank. Bank expects Third Parties to develop policies and procedures, as appropriate, to ensure their compliance with this Code. Third Party shall ensure that all officers, directors, employees, and subcontractors providing products or services to Bank are held to the same or even higher standards as contained in this Code. This Code is in addition to, and not in lieu of, any agreement between Third Party and Bank. A violation of the requirements of this Code will lead to a review and may result in termination of our relationship.
Ethical Business Practices
Third Party shall conduct its business activities with the highest standards of integrity and business ethics and in compliance with applicable law.
- Compliance with Laws
Third Party shall comply with all applicable laws, rules, and regulations (including federal, state, provincial and municipal) of the jurisdictions in which Third Party operates.
- Conflicts of Interest
Third Party shall refrain from attempting to gain improper advantage or preferential treatment. Third Party shall disclose any actual, potential, or perceived conflicts of interest to a representative of Bank’s Vendor Risk Management team as soon as Third Party becomes aware of a conflict. Conflicts of interest may arise from, but are not limited to, either business or personal relationships with customers, business associates, competitors of the Bank, or Bank employees.
- Gifts and Entertainment
Third Party shall not give or offer anything to Bank employees or representatives, the nature of which, by their quality, quantity, or timing may be perceived as an effort to influence actions, or to gain improper advantage or preferential treatment with Bank.
- Anti-Bribery and Anti-Corruption
Third Party shall comply with all applicable anti-bribery and anti-corruption laws. Third Party shall not solicit, give, offer, or accept, for themselves or any third party, anything of value from another person or entity, including but not limited to foreign government officials and employees of state-controlled enterprises, to influence or obtain an improper advantage, or to obtain or retain business.
- Insider Trading
Buying or selling securities while in possession of Material Non-Public Information that is acquired by virtue of the Third Party’s relationship with Bank is strictly prohibited, as is advising any other person to buy or sell such securities. Third Party shall not provide Material Non-Public Information to any third party accept as expressly permitted by written agreement with Bank for the purpose of the provision of products and/or services to Bank. Material non-public information includes all non-public information that is likely to affect the price of a security, or that a reasonable investor would likely consider important in making an investment decision.
- Safeguarding Information and Property
In the course of providing goods or services to Bank, Third Party may be provided or may obtain Bank customer non-public personal information, as defined in the Gramm-Leach-Bliley Act (15 U.S.C. §6801 et seq.) (“NPI”). Third Party shall protect the security and confidentiality of all NPI in accordance with the Gramm-Leach-Bliley Act (15 U.S.C. §§6801-6809) and the rules and regulations promulgated pursuant thereto, as well as other applicable local, state, and federal privacy laws, rules and regulations, such as the California Financial Information Privacy Act (Cal Financial Code § 4050, et seq.) (collectively hereafter, the “Privacy Laws”). Third Party agrees to maintain physical, electronic, and procedural safeguards that comply with Privacy Laws and to immediately disclose to Bank all breaches in security that may materially affect any person that is the subject of any NPI disclosed to Third Party.
- Business Continuity
Bank expects Third Party to have a business continuity and disaster recovery plan in place to ensure availability of critical services to Bank during an emergency event or disaster. As such, Third Party shall develop, maintain, and test its business continuity and disaster recovery plan to ensure the continued provision of critical services to Bank in the event of an emergency or force majeure event.
- Outsourcing & Subcontracting
Bank recognizes that outsourcing is a practice Third Party may use to promote innovation, fill resource gaps, and /or create operational efficiencies. Bank also recognize Third Party may need to use subcontractors in the performance of services. However, Third Party will not subcontract services where such outsource activities directly impact the delivery of good and services to Bank or where subcontractor will have access to NPI, without Bank’s prior written approval. In situations where approval is given, it is important for Bank to know the location of where the work will be performed, and the parties involved in the provisions of the services.
- Diversity and Inclusion
Third Party shall actively promote and maintain a diverse and inclusive workplace where each individual feels valued and is treated with dignity and respect. Additionally, Third Party shall strive for a diverse and inclusive supply chain by seeking to do business with diverse businesses. Examples of diverse vendors include minority and women owned businesses, businesses owned by individuals with disabilities, veteran owned businesses, and lesbian, gay, bisexual, or transgender owned businesses.
- Environment
Third Party shall operate in such a way as to protect and preserve the environment. Third Party is expected to conserve natural resources, avoid the use of hazardous materials, and promote activities that include the concepts of reuse and recycling. Third Party shall work to continually improve efficiency of resources and materials use. Third Party shall comply with all applicable environmental laws, regulations, and standards. Third Party shall cooperate with Bank by providing requested documents which may be needed to support Bank’s reporting requirements under its Environmental Social & Governance (ESG) initiative.
- Health and Safety
Third Party will provide a safe and healthy workplace, taking effective steps to prevent accidents, injuries, or exposure to health risks. Third Party will abide by all applicable local laws, directives and regulations relating to health and safety in the workplace. Third Party is also responsible for implementing changes to accommodate any amendments to applicable laws, rules, directives, or regulations. Third Party will have strict procedures that prevent the use of illegal drugs in the workplace.
- Labor and Human Rights
Third Party shall be committed to and have respect for the protection and preservation of human rights. Third Party shall be committed to the prevention of modern slavery and human trafficking in all aspects of its business. While it is Third Party’s responsibility to define Third Party’s policy and approach to the issue of human rights, Bank expects Third Party’s values and business principles to be consistent with those of Bank.
- Forced Labor
Third Party will not use forced or involuntary labor in any form (e.g., prison labor, indentured labor, bonded labor, or forced overtime) or otherwise engage in any practice that could reasonably be considered as employing or encouraging the same. All members of the workforce shall be free to leave the workplace or terminate their employment at any time.
- Child Labor
Third Party shall comply with all applicable child labor laws and employ only those individuals who meet the applicable minimum legal age requirement as prescribed by the relevant local authority.
- Fair Wage and Benefits
Third Party shall comply with all applicable wage and hour labor laws and regulations governing employee compensation, reimbursements, taxes and working hours.
- Discrimination
Third Party shall be an equal opportunity employer. Third Party shall provide an inclusive and nondiscriminatory working environment in which Third Party employees are valued and treated fairly, free from harassment, retaliation, intimidation, violence, and abuse of any kind, including but not limited to verbal, physical, visual sexual abuse or bullying behavior. Unlawful discrimination or harassment in the workplace is not tolerated. Discrimination or harassment on any grounds, including on the basis of sex, gender, creed, ethnicity, race, color, national origin, age, religion, citizenship, familial status, marital status, veteran status, sexual orientation, medical condition, disability, or any other factor protected under any applicable law is prohibited.
Compliance
Bank reserves the right to monitor Third Party for compliance with the requirements of this Code. Monitoring may include verification through self-assessments/questionnaires, requests for documentation, onsite audits, or other reasonable means of due diligence.
